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Case 1:20-cr-00330-PAE Document 287 Filed 05/20/21 Page 12 of 16 Finally, the government’s offer to provide Jencks Act and Giglio information for its testifying witnesses “as much as four weeks” before trial is insufficient. (Opp. 184). Certain of the Accusers and (we suspect) many of the government’s anticipated witnesses have made numerous statements about the events in question, either in the context of civil litigation, or to the media, or in other public fora. The defense will have to carefully analyze and compare any prior statements or impeachment material that the government discloses against the witness’s numerous public statements. This process will be time-consuming, but essential to Ms. Maxwell’s preparation for trial.° The Court has already acknowledged that the defense will need substantial time to evaluate and investigate materials related to potential witnesses in this case, and has ordered the government, over its objection, to produce certain Rule 16 materials related to non-testifying witnesses by March 12, 2021—four months in advance of trial—“‘to ensure that the defense can adequately prepare for trial.” (Dkt. 73). For the reasons set forth above, the Court should order the production of all of the requested materials by March 22, 2021. Til. The Court Should Grant Ms. Maxwell’s Request for Production and Inspection of Documents. Ms. Maxwell’s opening brief identified several redacted or incomplete documents that were produced in discovery, and documents that were omitted from discovery, that are subject to disclosure pursuant to the government’s Brady obligations. (Dkt. 148 at 7-10). The government represents that it has reviewed the documents and they do not contain any Brady material apart from one statement that the government now discloses in its opposition, or that it is under no ° The government has offered to provide any co-conspirator statements it intends to introduce at trial at the same time that it provides its Jencks Act disclosures. (Opp. 192). The defense requests that these statements be provided on the same accelerated timeline set forth above to provide sufficient time in the event that a pretrial hearing is necessary to determine their admissibility. DOJ-OGR-00004239